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Co-operative Compliance and the OECD’s International Compliance Assurance Programme by HEIN

Co-operative Compliance and the OECD’s International Compliance Assurance Programme

Edited by Ronald Hein, Ronald Russo
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Overview

EUCOTAX Series on European Taxation, Volume Number 68.

Co-operative Compliance and the OECD’s International Compliance Assurance Programme is the first publication to analyse Co-operative Compliance and the International Compliance Assurance Programme (ICAP) in twelve different jurisdictions. Prominent among initiatives addressing the urgent need for a common understanding between multinational enterprises (MNEs) and national tax authorities about risks and risk assessment is the ICAP, which provides a channel for MNEs to engage in simultaneous discussions with multiple national tax administrations, thus enhancing the potential for advance tax assurance. To a certain extent, the ICAP represents the internationalization of Co-operative Compliance frameworks which were, until then, restricted within the borders of single jurisdiction.

What’s in this book:
Following a general introduction, the book presents two opening perspectives on the ICAP, one from the OECD and the other from a participating tax administration (the Netherlands), leading to the twelve country reports and a special chapter on transfer pricing, which is the main issue in international tax disputes. Specific elements reviewed include the following:

  • criteria to enter the programme;
  • range of taxes covered by the programme;
  • real-time consultation procedures;
  • appeal procedures within the programme;
  • the possibility to ‘agree to disagree’ and to continue Co-operative Compliance even in cases of litigation;
  • risk-management strategies within tax authorities;
  • corporate administrative compliance burden; and
  • main sources of tax uncertainty.

Each report addresses the same questions so that all the reports cover, to some extent, the same features of their domestic relationship approaches and their ICAP experiences. A final chapter puts forward the reviews on the contributions and offers some concluding remarks.

How this will help you:
Although the ICAP process probably will undergo further adjustments, it is certain that the road to more international cooperation between tax authorities and MNEs is now open. This timely book, as a comparative review of the implementation of the ICAP among leading jurisdictions active in global trade, provides matchless insights into trends, similarities, differences and their implications. With country reports contributed by tax academics and professionals experienced in dealing with Co-operative Compliance and the ICAP, this book will be welcomed by all stakeholders in the international tax community, including lawyers, taxation authorities and academics.

Last Updated 04/30/2020
Product Line Kluwer Law International
ISBN 9789403519517
SKU 10081640-0001
Table of Contents

Preface

CHAPTER 1
Introduction: An investigation of Co-operative Compliance regimes and the ICAP

CHAPTER 2
The International Compliance Assurance Programme (ICAP)

CHAPTER 3
The ICAP experience: A tax authority perspective

CHAPTER 4
Co-operative Compliance Programs in Australia: Working Towards Justified Trust

CHAPTER 5
Co-operative Compliance: An Austrian point of view

CHAPTER 6
Canada’s experience with the ICAP

CHAPTER 7
Does Co-operative Compliance fit into the German compliance environment?

CHAPTER 8
From Tax Rulings to Co-operative Compliance: a New Deal between the Taxpayer and the Italian Tax Administration?

CHAPTER 9
Japanese International Compliance Assurance in Practice

CHAPTER 10. Co-operative Compliance in Norway

CHAPTER 11
Co-operative Compliance and ICAP in the Netherlands

CHAPTER 12
Co-operation Program: a Novelty in the Polish Tax System

CHAPTER 13
Hard Law and Soft Law Measures Implemented by Spain Regarding Co-operative Compliance

CHAPTER 14
Co-operative Compliance: The UK Evolutionary Model

CHAPTER 15
The U.S. Compliance Assurance Program and Comparative Lessons

CHAPTER 16
Transfer Pricing practical experience: Preventing double taxation – analysis of recent developments and ICAP 2.0

CHAPTER 17
Concluding remarks and observations

Index

Volumes